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 July 29, 2025

Wah Fu
Chief Executive Officer
International Endeavors Corporation
Unit 2, Level 6
Westin Centre
26 Hung To Road
Kwun Tong, Hong Kong

 Re: International Endeavors Corporation
 Amendment No. 1 to Registration Statement on Form 10-12G
 Filed July 3, 2025
 File No. 000-55649
Dear Wah Fu:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in
response to this
letter, we may have additional comments.

Amendment No. 1 to Registration Statement on Form 10-12G filed July 3, 2025
Introductory Comment, page iii

1. Please revise to clearly state whether you conduct any operations
through a variable
 interest entity. In this regard, we note your disclosure here that you
conduct operations
 through your wholly owned subsidiaries based in Hong Kong and an
affiliated
 company in Australia. However, in Note 2 to your financial statements on
page F-28,
 you refer to the company s subsidiaries and variable interest entity.
2. Where you discuss the Holding Foreign Companies Accountable Act (HFCAA),
 please revise to clarify that the HFCAA, as amended by the Consolidated
 Appropriations Act, 2023, decreased the number of consecutive
non-inspection years
 triggering the trading prohibition from three years to two years. Please
also revise
 similar disclosures on pages vi and 29-30.
 July 29, 2025
Page 2

Business, page 1

3. Please revise the organizational chart on page 1 to also reflect
ModuLink Inc.'s
 preferred ownership interest in you and your directors' interests in
ModuLink Inc., as
 you discuss on page 2 and elsewhere.
4. Please clarify the statement on page 2 that "we believe that our current
cash and other
 sources of liquidity discussed below are adequate to support operations
for at least the
 next 12 months." In this regard we note that two promissory notes in the
amount
 of $124,549 are past due, see page 26, and we note that cash flow from
operations was
 negative, see page F-5. Please also include a discussion of this default
in the MD&A
 section.
5. We note that most of your revenues appear related to specific projects,
such as those
 included in the tables on page 7, which we note does not include any
projects after
 2023. Please revise to also provide more details regarding the specific
material
 projects undertaken in 2024 and currently being undertaken by the
company. For
 those projects currently being undertaken, please describe the material
terms of each
 individual contract including the term length (multi-year, one year,
etc.), specific
 details of the planned construction and services provided, and any
material provisions
 or conditions that may affect the completion of the project.
Management's Discussion and Analysis of the Results of Operations, page 40

6. When discussing the results of operations, please discuss in greater
detail the reasons
 for the changes in the line items. For example, please explain the
underlying reasons
 for the drop in revenue derived from the design and build services. See
Item 303(b) of
 Regulation S-K.
Item 5. Directors and Executive Officers, page 55

7. Please ensure that you have described the business experience during the
past five
 years of each of your directors and executive officers, including each
person's
 principal occupations and employment during the past five years and the
name and
 principal business of any corporation or other organization in which
such occupations
 and employment were carried on. See Item 401(e) of Regulation S-K.
Executive Compensation, page 58

8. We note the disclosure on page 58 regarding base salaries and the
disclosure on page
 59 that you have agreed to pay Messrs. Fu and Au-Yeung a monthly fee of
 HK$20,000 (approximately $2,564) and HK$10,000 (approximately $1,282)
for their
 services. However, the summary compensation table does not reflect any
base salary.
 Please advise or revise. To the extent that compensation was deferred,
please include
 the amount in the appropriate column of the table. See Instruction 4 to
Item 402(n) of
 Regulation S-K. Please reconcile or advise regarding similar
inconsistency with the
 director compensation. Please also revise the narrative following the
summary
 compensation table and director compensation table to explain what is
included in the
 all other compensation column.
 July 29, 2025
Page 3
Item 7. Certain Relationships and Related Transactions, and Director
Independence, page 61

9. Please expand to disclose all of the information required by Item
404(a)(5) of
 Regulation S-K for the two promissory notes held by Zenith HK.
10. As applicable, please file as an exhibit any material contract related
to the transactions
 with Leidenford Ltd. See Item 601(b)(10) of Regulation S-K.
Item 9. Market Price of and Dividends of the Registrant's Common Equity and
Related
Stockholder Matters, page 64

11. Please revise to disclose, if true, that your securities are quoted on
the OTCID Basic
 Market. As applicable, please also revise your references to the
Over-the-Counter-
 Bulletin-Board on pages iii and 2.
Index to Consolidated Financial Statements, page F-1

12. It appears you have presented consolidated financial statements of
International
 Endeavors Corporation and ModuLink Investment Limited as of and for the
years
 ended December 31, 2024 and 2023, and as of and for the three months
ended March
 31, 2025 and 2024. We note your disclosure on page F-6 that there was a
change of
 control in early 2025. In light of this change of control, we are
unclear how you
 determined it was appropriate to present financial statements as if the
share exchange
 had occurred at the beginning of the earliest reporting period
presented. Please advise,
 or revise to separately present audited financial statements of
International Endeavors
 Corporation in accordance with Article 8 of Regulation S-X, as required
by Item 13 of
 Form 10.
Exhibits

13. Please re-file Exhibit 10.6 in accordance with Item 601(b)(10)(iv) of
Regulation S-K.
 In this regard, we note that you have redacted certain provisions of the
agreement.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters.
Please contact Benjamin Holt at 202-551-6614 or Pam Howell at 202-551-3357 with
any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Jenny Chen-Drake
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